Information We Collect

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Visably app (the “App”), available to users worldwide and designed to help users track and plan their stays in the Schengen Area.

Please read this Privacy Policy carefully. If you do not agree with the terms of this privacy policy, please do not access the App.

WHO WE ARE

NCKY Ltd ("we", "us", or "our") is a company registered in the United Kingdom that operates the App and acts as the data controller. If you have questions or concerns about this Privacy Policy, please contact us at:

• Email: hello[at]ncky.dev
• Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ

INFORMATION WE COLLECT

We may collect the following personal information (or personal data, as termed in some regions), some of which may possibly be sensitive:

• Contact Data: Information such as your name and email address, voluntarily provided when you create an account or contact us.
• Profile Data: Details you provide when setting up your account, such as your name or username.
• Travel Data: Dates and destinations you input to track and plan your Schengen stays, including data entered offline and synced when you’re online.
• Location Data: Information about your location, if you choose to enable the automatic trip tracking feature in your settings, to assist with travel planning or tracking.
• Technical Data: Information like device type, IP address, operating system, unique device identifiers, and device tokens if you enable push notifications.
• Usage Data: Information about how you use the App, such as features accessed.

We collect this directly from you (e.g., when you input data or use the App), indirectly (e.g., through your device activity), or from third parties. Additionally, when you download or use the App via the App Store, Apple may independently collect data such as device information, purchase history, or usage statistics under their own privacy policies.

The App is not intended for children under 16. We do not knowingly collect data from children under 16, and we will delete such data if we discover it has been collected.

HOW WE USE YOUR INFORMATION

We may use your personal data for the following purposes:

• To provide the app's core features, such as tracking and planning your Schengen stays.
• To manage your account, including creating it, logging you in, and verifying your subscription.
• To process payments and manage subscription renewals.
• To respond to your inquiries and resolve any issues you raise.
• To send you technical notices, updates, security alerts, support messages, or Schengen stay limit alerts via push notifications (if you enable them).
• To maintain the app’s technical functionality and ensure it runs smoothly.
• To protect the app from illegal, unauthorized, or fraudulent use.
• To conduct analytics, such as measuring how often features are used to improve the app or understand our audience.
• To comply with legal obligations and respond to lawful requests from public authorities.

LEGAL BASIS FOR PROCESSING

We process your personal data based on:

• Contract: To provide the services you expect from the App and verify your subscription.
• Legitimate Interests: For purposes like improving the App or ensuring security, where this doesn’t override your rights.
• Consent: Where you’ve agreed to processing, such as by enabling features or ticking a box. You can withdraw consent at any time via App settings or by contacting us; we’ll stop processing unless another legal basis applies.
• Legal Obligation: When required by law.

SECURITY OF YOUR PERSONAL DATA

We use appropriate technical and organizational measures, such as encryption and access controls, to protect your personal data from unauthorized access, loss, or misuse. However, no electronic transmission over the Internet or storage system can be guaranteed 100% secure, so we cannot promise absolute security despite our efforts. We encourage you to keep your account credentials confidential and avoid sharing highly sensitive information to help safeguard your personal information.

TRANSFER OF YOUR PERSONAL DATA

We do not sell your personal data, but may share or transfer your personal data with the following service providers:

• RevenueCat: To manage subscriptions. See their privacy policy at https://www.revenuecat.com/privacy.
• Apple: To process payments for subscriptions; payment details are handled directly by Apple. We do not handle, store, or access this payment data ourselves. For more details, see Apple’s privacy policy at https://www.apple.com/legal/privacy/.
• Hosting provider: To store and process app data on secure servers in the EU.

We may also share data when required by law or to protect our rights. We do not share your data with other third parties for marketing purposes.

Your data may be transferred to and stored on systems outside your state, province, country, or jurisdiction, such as in the European Union (EU) or United States (US), where data protection laws may differ. We ensure that appropriate safeguards are in place to protect your data.

RETENTION OF YOUR PERSONAL DATA

We keep your personal data only as long as necessary to fulfill the purposes we collected it for, such as providing the App’s services, unless we must retain it longer for legal compliance, financial record-keeping, dispute resolution, or other legitimate business purposes.

YOUR RIGHTS

You may have the following data protection rights, depending on your location:

• Right to Confirm: You can confirm whether we process your personal information.
• Right to Access/Know: You can request details about the personal information we process about you, including categories, sources, purposes, and recipients (covering the past 12 months, if requested), typically at no cost.
• Right to Rectification: You can review and request corrections to any inaccurate or incomplete personal information we hold.
• Right to Erasure: You can request deletion of your personal information in certain cases, such as when it’s no longer needed for our services or if you withdraw consent.
• Right to Restrict or Anonymize: You can request restriction or anonymization of processing in specific cases, such as when you dispute data accuracy or object to its use.
• Right to Data Portability: You can request your personal information in a commonly used, machine-readable format, or have it transferred to another provider, where technically feasible.
• Right to Limit Sensitive Data: You can limit our use of sensitive personal information, where applicable.
• Right to Withdraw Consent: You can withdraw consent to processing at any time, without affecting prior processing.
• Right to Object: You can object to processing of your personal data, including for direct marketing, if applicable, or where based on our legitimate interests.
• Right to Review Automated Decisions: You can request a review of automated decisions affecting you legally or significantly (if applicable).
• Right to Non-Discrimination: We won’t discriminate against you for exercising these rights.
• Right to Lodge a Complaint: You can file a complaint with the local data protection authority.

To exercise these rights, or for questions or complaints about your privacy, contact us at hello[at]ncky.dev. We’ll confirm receipt within 10 days and respond promptly: access requests within 15 days (or up to 45 days if needed, with explanation), other requests as soon as reasonably possible. We’ll notify third parties of corrections or deletions unless impractical. If we can’t comply, we’ll explain why. Requests are free unless excessive or unfounded, with justification for any cost or refusal.

LINKS TO OTHER WEBSITES

Our App may contain links to third-party websites or services not operated by us. If you click a third-party link, you’ll be directed to their site. We recommend reviewing the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time and for any reason. We’ll notify you of changes by updating the “Last Updated” date above. You’re encouraged to review this policy periodically to stay informed. Your continued use of the App after changes means you accept the updated policy.